That's one point of view, but it works. Of course sender should research the audience properly, and provide one-click unsubscribe option right at the top.
My dictionary describes spam as "irrelevant or unsolicited messages sent over the internet, typically to a large number of users, for the purposes of advertising, phishing, spreading malware, etc.."
Unsolicited messages sent over the internet is exactly what @twosdai is doing.
That would mean all database providers are basically spam enablers!